# AMLR Monitor

> AMLR Monitor tracks the status of every Regulatory Technical Standard (RTS), Guideline and Implementing Technical Standard (ITS) under the EU AML package (AMLR, AMLD6, AMLAR), mapped onto a compliance framework, and shows what the AMLR rules mean for your organisation: AI impact assessment, country-specific points, readiness tracking and a board report. Free monitor, daily checks of EBA and AMLA sources.

Site: https://www.amlr-monitor.com
Pages: https://www.amlr-monitor.com/features (what the tool does), https://www.amlr-monitor.com/pricing (plans and prices per organisation), https://www.amlr-monitor.com/terms and https://www.amlr-monitor.com/privacy (terms of service and privacy statement; AMLR Monitor is an initiative of Castor Concepts BV), https://www.amlr-monitor.com/#contact (contact form), https://www.amlr-monitor.com/who-must-comply (every type of obliged entity under Art. 3 AMLR, grouped by sector, with scope, application date and key framework blocks), https://www.amlr-monitor.com/blog (articles, RSS at https://www.amlr-monitor.com/blog/feed.xml).

## Languages

The front page, the product page and the blog exist in English, Dutch, French, German and Spanish; every page links its language versions with hreflang. Blog articles are written in English and translated into the other four languages.
- English (en): front page https://www.amlr-monitor.com/, product page https://www.amlr-monitor.com/features, pricing https://www.amlr-monitor.com/pricing, blog https://www.amlr-monitor.com/blog. Topic pages: The AMLR rules: what they are, where they stand, when they apply: https://www.amlr-monitor.com/amlr-rules; AMLR for your organisation: what applies to you, and what to do about it: https://www.amlr-monitor.com/amlr-for-your-organisation; AMLR specialists: expertise on the EU AML Regulation, on demand: https://www.amlr-monitor.com/amlr-specialists; What is the AMLR?: https://www.amlr-monitor.com/what-is-the-amlr; When does the AMLR apply? The timeline to 10 July 2027 and beyond: https://www.amlr-monitor.com/amlr-application-date; AMLR vs AMLD6 vs national law: what is the difference?: https://www.amlr-monitor.com/amlr-vs-amld6-and-national-law; AMLR compliance checklist: what to have in place before 10 July 2027: https://www.amlr-monitor.com/amlr-compliance-checklist
- Nederlands (nl): front page https://www.amlr-monitor.com/nl, product page https://www.amlr-monitor.com/nl/features, pricing https://www.amlr-monitor.com/nl/pricing, blog https://www.amlr-monitor.com/nl/blog. Topic pages: De AMLR-regels: wat ze zijn, waar ze staan, wanneer ze gelden: https://www.amlr-monitor.com/nl/amlr-regels; AMLR voor mijn organisatie: wat geldt voor u, en wat u ermee moet doen: https://www.amlr-monitor.com/nl/amlr-voor-mijn-organisatie; AMLR-specialisten: expertise over de EU-antiwitwasverordening, op afroep: https://www.amlr-monitor.com/nl/amlr-specialisten; Wat is de AMLR?: https://www.amlr-monitor.com/nl/wat-is-de-amlr; Wanneer geldt de AMLR? De tijdlijn naar 10 juli 2027 en daarna: https://www.amlr-monitor.com/nl/amlr-ingangsdatum; AMLR versus AMLD6 versus Wwft: wat is het verschil?: https://www.amlr-monitor.com/nl/amlr-versus-amld6-en-wwft; AMLR-checklist: wat vóór 10 juli 2027 op orde moet zijn: https://www.amlr-monitor.com/nl/amlr-checklist
- Français (fr): front page https://www.amlr-monitor.com/fr, product page https://www.amlr-monitor.com/fr/features, pricing https://www.amlr-monitor.com/fr/pricing, blog https://www.amlr-monitor.com/fr/blog. Topic pages: Les règles AMLR : ce qu'elles sont, où elles en sont, quand elles s'appliquent: https://www.amlr-monitor.com/fr/regles-amlr; L'AMLR pour votre organisation : ce qui s'applique à vous, et quoi en faire: https://www.amlr-monitor.com/fr/amlr-pour-mon-organisation; Spécialistes AMLR : l'expertise sur le règlement anti-blanchiment de l'UE, à la demande: https://www.amlr-monitor.com/fr/specialistes-amlr
- Deutsch (de): front page https://www.amlr-monitor.com/de, product page https://www.amlr-monitor.com/de/features, pricing https://www.amlr-monitor.com/de/pricing, blog https://www.amlr-monitor.com/de/blog. Topic pages: Die AMLR-Regeln: was sie sind, wo sie stehen, ab wann sie gelten: https://www.amlr-monitor.com/de/amlr-regeln; AMLR für Ihre Organisation: was für Sie gilt, und was daraus folgt: https://www.amlr-monitor.com/de/amlr-fuer-meine-organisation; AMLR-Spezialisten: Expertise zur EU-Geldwäscheverordnung, auf Abruf: https://www.amlr-monitor.com/de/amlr-spezialisten
- Español (es): front page https://www.amlr-monitor.com/es, product page https://www.amlr-monitor.com/es/features, pricing https://www.amlr-monitor.com/es/pricing, blog https://www.amlr-monitor.com/es/blog. Topic pages: Las normas AMLR: qué son, dónde están, cuándo se aplican: https://www.amlr-monitor.com/es/normas-amlr; El AMLR para su organización: qué le aplica, y qué hacer al respecto: https://www.amlr-monitor.com/es/amlr-para-mi-organizacion; Especialistas AMLR: experiencia en el Reglamento antiblanqueo de la UE, bajo demanda: https://www.amlr-monitor.com/es/especialistas-amlr
Statuses last reviewed: 2026-09-21. The AMLR applies from 2027-07-10.

## Topic pages (English; Dutch versions linked with hreflang)

- The AMLR rules: what they are, where they stand, when they apply: https://www.amlr-monitor.com/amlr-rules
- AMLR for your organisation: what applies to you, and what to do about it: https://www.amlr-monitor.com/amlr-for-your-organisation
- AMLR specialists: expertise on the EU AML Regulation, on demand: https://www.amlr-monitor.com/amlr-specialists
- What is the AMLR?: https://www.amlr-monitor.com/what-is-the-amlr
- When does the AMLR apply? The timeline to 10 July 2027 and beyond: https://www.amlr-monitor.com/amlr-application-date
- AMLR vs AMLD6 vs national law: what is the difference?: https://www.amlr-monitor.com/amlr-vs-amld6-and-national-law
- AMLR compliance checklist: what to have in place before 10 July 2027: https://www.amlr-monitor.com/amlr-compliance-checklist

## What the tool does

Full overview: https://www.amlr-monitor.com/features
- Status of every RTS, Guideline and ITS (public dashboard): One screen with every Level-2 and Level-3 instrument under the AMLR, AMLD6 and AMLAR: in consultation, closed, final or published, with consultation deadlines, expected dates, a summary, the impact and links to the EBA, AMLA and EUR-Lex source.
- Mapped onto a compliance framework (public dashboard): Instruments are placed on the framework blocks they affect (business-wide risk assessment, governance, customer due diligence, monitoring, reporting, data and systems), so you see at a glance where the regulatory pressure sits.
- Filter by type of obliged entity (public dashboard): Banks, lenders and leasing companies, payment and e-money institutions, crypto-asset service providers, insurers, investment firms, trust offices, accountants, lawyers, notaries, real-estate agents, traders in goods and football clubs each see only the instruments that apply to them, with their own application date.
- Article browser and "what changes" notes (public dashboard): Every article reference links to the text on EUR-Lex, and every framework block explains what changes compared with the current national law (for the Netherlands: the Wwft).
- Daily source check (workspace, sign-in): EBA, AMLA, EUR-Lex, DNB, AFM, FIU-Netherlands and the Dutch ministry pages are fetched every day; new AML-related publications are listed in the workspace and can be sent by e-mail, Slack or Teams.
- Company profile with AI impact assessment (workspace, sign-in): Type the name of your organisation; the AI looks it up, asks you to confirm, fills in the profile and produces an AMLR impact assessment: priority blocks, blocks that do not apply, matching documents and country-specific points.
- Readiness tracker and heat map (workspace, sign-in): Per framework block a status, owner, target date and notes; the front page then shows your own readiness as a heat map over the framework. Analysis, roadmap and a print-ready board report come out of the same data.
- Country-specific points for every EU country (workspace, sign-in): Editorial points for the Netherlands, Belgium, Germany, Luxembourg, France, Ireland, Spain and Italy, and AI-researched points for any other EU/EEA country your organisation operates in, with a country filter in the workspace.
- AI consultant that knows your organisation (workspace, sign-in): Ask questions about the AMLR, the RTS and guidelines or your own readiness; the answers use your profile, readiness and selected points, and follow-up actions go straight onto your task list.
- Team workspace with consultations, tasks and audit log (workspace, sign-in): Invite colleagues into the same organisation, track consultation responses and internal deadlines, keep personal task lists, export CSVs and see every change in the audit log.
- Alerts when a source changes (workspace, sign-in): Pick the framework blocks you follow and get an e-mail, Slack or Teams message when the daily check finds a new consultation, final draft or publication.
- Personal task list (workspace, sign-in): Follow-ups from consultant answers and assessment priorities land on your own list with due dates, next to tasks you add yourself.
- Board report and exports (workspace, sign-in): A print-ready readiness report for the board and CSV exports of readiness, instruments, consultations, the compliance log and the audit log.
- Compliance log and printable report for supervisors (workspace, sign-in): Record every measure taken to become compliant (policy, procedure, control, training, system change, risk assessment, decision) with date, owner, framework block and evidence reference; one click produces a formal compliance report with signature block to print or save as PDF for the supervisor.
- AI help on every block, instrument, consultation and roadmap (workspace, sign-in): Next to each framework block, tracked instrument, consultation response and the roadmap sits an AI button that thinks along with your profile and progress in mind; suggested follow-ups go straight onto your task list.
- Advisor role for several organisations (workspace, sign-in): Advisors and consultants work for several client organisations from one account and switch between them; whoever creates an organisation is its administrator and can appoint other administrators and members.
- Encrypted and protected (workspace, sign-in): Everything your organisation enters is encrypted field by field before it is stored; two-factor authentication with an authenticator app, optionally required for the whole organisation.

## Blog (articles on the AMLR, a new one every few days)

- 2026-09-18: The RTS on sanctions is final: how supervisors will grade and price breaches - AMLA's final draft RTS under Article 53(10) AMLD6 gives supervisors a four-step method to grade breaches and set fines. What it means for obliged entities. https://www.amlr-monitor.com/blog/rts-pecuniary-sanctions-gravity-breaches-final-draft-amla
- 2026-09-14: Comply-or-explain: how AMLA guidelines bind supervisors and obliged entities - AMLA guidelines are not law, but they are not optional either. What Article 54 AMLAR means for supervisors and firms, and how to handle the pipeline of guidelines still to come. https://www.amlr-monitor.com/blog/comply-or-explain-how-amla-guidelines-bind-supervisors-and-obliged-entities
- 2026-09-10: What changes on 10 July 2027: the AMLR in ten obligations - From 10 July 2027 the EU Anti-Money Laundering Regulation applies directly. Ten obligations that change the day-to-day work of obliged entities, with the articles and what to do now. https://www.amlr-monitor.com/blog/what-changes-on-10-july-2027-ten-amlr-obligations
- 2026-09-06: Six weeks after the first tranche: where AMLA's standards stand - A status check in early September 2026: seven final reports, seven consultations closed and being finalised, three open, a dozen guidelines not yet drafted. What is settled, what is not, and what obliged entities should do this quarter. https://www.amlr-monitor.com/blog/six-weeks-after-the-first-tranche-where-amlas-standards-stand
- 2026-09-02: The ITS on the suspicious transaction report: prepare your data now - AMLA consulted (2 July to 20 September 2026) on the implementing technical standard that fixes the template for reporting suspicious transactions to FIUs. What the template will ask for and how to get your data ready. https://www.amlr-monitor.com/blog/its-suspicious-transaction-report-template-prepare-your-data
- 2026-08-29: The Guidelines on the business-wide risk assessment: what the consultation asks of you - AMLA consulted on Guidelines for the business-wide risk assessment under Article 10 AMLR until 15 July 2026 and is finalising them. The structure they expect, the link to the supervisory methodology and what changes for institutions with a SIRA. https://www.amlr-monitor.com/blog/guidelines-business-wide-risk-assessment-consultation
- 2026-08-25: Ongoing monitoring under the AMLR: review frequencies and event-driven reviews - Article 26 AMLR makes ongoing monitoring a duty with fixed elements, and AMLA consulted on Guidelines for it until 3 September 2026. How periodic reviews, event-driven reviews and transaction monitoring fit together. https://www.amlr-monitor.com/blog/ongoing-monitoring-guidelines-review-frequencies
- 2026-08-21: Who will AMLA supervise directly in 2028? The selection methodology explained - The RTS on the selection of obliged entities for direct AMLA supervision, submitted to the Commission, sets the criteria: cross-border activity and inherent risk. What the first selection round means for candidate institutions. https://www.amlr-monitor.com/blog/amla-direct-supervision-selection-methodology-2028
- 2026-08-17: The compliance manager at board level: who, what and how to evidence it - Article 11 AMLR requires a compliance manager in the management body next to the compliance officer. What the role involves, how it differs from the compliance officer and what supervisors will ask to see. https://www.amlr-monitor.com/blog/compliance-manager-board-level-article-11
- 2026-08-13: The 25% beneficial ownership threshold and control through other means - Articles 51 to 56 AMLR replace national thresholds with one rule: 25% ownership, plus control through other means, traced through multi-layered structures. What to collect, verify and record from 10 July 2027. https://www.amlr-monitor.com/blog/beneficial-ownership-25-percent-threshold-control-other-means
- 2026-08-09: Outsourcing and reliance under the AMLR: what may leave the building and what must stay - Article 18 sets hard limits on outsourcing AML tasks; Articles 48 and 49 govern reliance on other obliged entities. Which tasks stay in-house, what contracts must contain and what AMLA's planned Guidelines will add. https://www.amlr-monitor.com/blog/outsourcing-and-reliance-what-stays-in-house
- 2026-08-05: Politically exposed persons under the AMLR: the twelve-month rule and the lists of prominent public functions - Articles 42 to 46 AMLR harmonise who counts as a PEP, require Member States to publish lists of prominent public functions and keep measures in place for at least twelve months after office. What changes for screening and reviews. https://www.amlr-monitor.com/blog/politically-exposed-persons-12-month-rule-lists
- 2026-08-01: Sanctions screening becomes a customer due diligence measure (Article 27 AMLR) - The AMLR makes verifying whether a customer or beneficial owner is subject to EU targeted financial sanctions part of due diligence. What it means for onboarding, list updates and sectors new to screening. https://www.amlr-monitor.com/blog/sanctions-screening-as-customer-due-diligence-article-27
- 2026-07-28: Enhanced due diligence for high-net-worth customers: the €50 million and €5 million tests - Article 34 AMLR requires enhanced measures for customers with wealth of at least €50 million or assets of at least €5 million handled by the institution. Source of wealth, senior approval and what private banks must change. https://www.amlr-monitor.com/blog/enhanced-due-diligence-high-net-worth-50-million
- 2026-07-24: Crypto under the AMLR: correspondent relationships with CASPs and self-hosted addresses - Articles 37 and 38 AMLR set enhanced measures for relationships with crypto-asset service providers and for transactions with self-hosted addresses. What CASPs and the banks that serve them must do. https://www.amlr-monitor.com/blog/crypto-correspondent-relationships-self-hosted-addresses
- 2026-07-20: Group-wide policies and third-country branches: managing conflicting laws under the AMLR - Articles 16 and 17 AMLR require parent undertakings to implement group-wide policies, including information sharing, and to manage branches in third countries whose law is less strict or forbids the group policy. https://www.amlr-monitor.com/blog/group-wide-policies-third-country-branches-articles-16-17
- 2026-07-16: Simplified due diligence under the AMLR: when low risk really is low - Article 33 AMLR allows simplified measures only after a documented low-risk assessment and never where suspicion exists. What simplified means, which factors count and what the CDD RTS specifies. https://www.amlr-monitor.com/blog/simplified-due-diligence-when-low-risk-is-low
- 2026-07-12: The first tranche of RTS is with the Commission: what happens next - 10 July 2026 was the statutory deadline for the first tranche of technical standards: AMLA delivered some of them and rescheduled the rest. How adoption, scrutiny and publication work, and what obliged entities can already do. https://www.amlr-monitor.com/blog/first-tranche-rts-at-the-commission-what-happens-next
- 2026-07-08: One year to go: a twelve-month plan to 10 July 2027 - With twelve months left before the AMLR applies, a quarter-by-quarter plan for an obliged entity: gap analysis, design, build, test, and the evidence supervisors will want to see on day one. https://www.amlr-monitor.com/blog/twelve-month-plan-to-10-july-2027
- 2026-07-04: Record retention under the AMLR: five years, then deletion, and the data-protection balance - The AMLR sets a five-year retention period for customer due diligence and transaction records and requires deletion afterwards. How to reconcile it with GDPR, litigation holds and the reporting template. https://www.amlr-monitor.com/blog/record-retention-five-years-data-protection (fr: https://www.amlr-monitor.com/fr/blog/record-retention-five-years-data-protection, nl: https://www.amlr-monitor.com/nl/blog/record-retention-five-years-data-protection, es: https://www.amlr-monitor.com/es/blog/record-retention-five-years-data-protection, de: https://www.amlr-monitor.com/de/blog/record-retention-five-years-data-protection)
- 2026-06-30: The Dutch implementation act for the AML package: what stays national - The Netherlands is consulting on the Implementatiewet AML-pakket that implements AMLD6 and adjusts the Wwft. What remains national next to the directly applicable AMLR: supervisors, FIU-Netherlands, registers, sanctions and the cash limit. https://www.amlr-monitor.com/blog/dutch-implementation-act-what-stays-national (fr: https://www.amlr-monitor.com/fr/blog/dutch-implementation-act-what-stays-national, es: https://www.amlr-monitor.com/es/blog/dutch-implementation-act-what-stays-national, nl: https://www.amlr-monitor.com/nl/blog/dutch-implementation-act-what-stays-national, de: https://www.amlr-monitor.com/de/blog/dutch-implementation-act-what-stays-national)
- 2026-06-26: The €10,000 cash limit and what it means for traders in goods and services - The AMLR caps cash payments at €10,000 for traders in goods and services across the EU, with Member States free to set a lower limit. Who is affected, what must be refused and what obliged entities must record. https://www.amlr-monitor.com/blog/cash-limit-10000-euro-traders-in-goods (de: https://www.amlr-monitor.com/de/blog/cash-limit-10000-euro-traders-in-goods)

## Instruments and status

- Level-1 legislation: Anti-Money Laundering Regulation (AMLR) (Entire text). Status: Published. Expected 2027-07-10. The "single rulebook": directly applicable obligations for obliged entities. Largely replaces the national Wwft obligations from 10 July 2027. Source: https://eur-lex.europa.eu/eli/reg/2024/1624/oj
- Level-1 legislation: Sixth Anti-Money Laundering Directive (AMLD6) (Entire text). Status: Published. Expected 2027-07-10. Governs supervision, FIUs, beneficial ownership registers and cooperation between authorities. Must be transposed into national law by the Member States. Source: https://eur-lex.europa.eu/eli/dir/2024/1640/oj
- Level-1 legislation: AMLA Regulation (AMLAR) (Entire text). Status: Published. Establishes the European AML authority (AMLA, Frankfurt), operational since 1 July 2025; the EBA's AML/CFT mandates transferred to it on 1 January 2026. AMLA develops the RTS/ITS/Guidelines (40 mandates, 24 of them planned for 2026 in its Single Programming Document) and will directly supervise up to 40 cross-border credit and financial institutions selected in 2027, from 2028. Source: https://eur-lex.europa.eu/eli/reg/2024/1620/oj
- Regulatory Technical Standard: RTS on customer due diligence (CDD) (Art. 28(1) AMLR). Status: Consultation closed, being finalised. Consultation closed/closes 2026-05-08. Expected 2026-09-30. Specifies which information must be collected and verified when identifying the customer and beneficial owner, which reliable sources may be used, and the requirements for simplified and enhanced due diligence. The EBA consulted a first draft in 2025; AMLA re-consulted its own draft from 9 February to 8 May 2026 (public hearing 24 March 2026). The statutory deadline of 10 July 2026 was adjusted: AMLA's programming document schedules the final draft for Q3 2026 and submission to the Commission in 2026. No final report yet. Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-rts-customer-due-diligence_en
- Regulatory Technical Standard: RTS on the assessment of the inherent and residual risk profile of obliged entities (financial sector) (Art. 40(2) AMLD6). Status: Final text, awaiting publication. Consultation closed/closes 2025-06-06. Expected 2026-12-31. Harmonised methodology supervisors use to rate the inherent and residual ML/TF risk of credit and financial institutions: the data points, risk indicators, weighting and the resulting risk categories. Final report published by AMLA on 16 December 2025 and sent to the Commission; the Commission's Legal Service asked for clarifications and AMLA aims to finalise the RTS before the end of 2026 (General Board, 1 July 2026). The non-financial sector has its own draft RTS under the same article, in consultation since July 2026. Source: https://www.amla.europa.eu/document/download/c8782141-45bf-4ef9-9d66-33e2f90e607e_en?filename=1.1_20251216_FINAL+REPORT+RTS+40%282%29+AMLD+financial+only_Final.pdf
- Regulatory Technical Standard: RTS on the selection of obliged entities for direct AMLA supervision (Art. 12 AMLAR). Status: Final text, awaiting publication. Consultation closed/closes 2025-06-06. Expected 2026-12-31. Methodology for determining the inherent and residual risk profile of credit and financial institutions operating in at least six Member States, on the basis of which AMLA selects up to 40 entities for direct supervision. Final report published 16 December 2025 and sent to the Commission, which asked for clarifications; AMLA aims to finalise the RTS before the end of 2026. Timeline: eligibility data collected through national supervisors (at AMLA by 15 August 2026, provisional list by end-September 2026), selection data from January to March 2027 with reference date 31 December 2026, selection from 1 July 2027 with the outcome communicated by the end of 2027, direct supervision during 2028. Source: https://www.amla.europa.eu/system/files/2025-12/2.1_20251216_Final%20report%20-%20RTS%20under%20art.%2012(7)%20AMLAR.pdf
- Regulatory Technical Standard: RTS on pecuniary sanctions, administrative measures and periodic penalty payments (Art. 53(10) AMLD6). Status: Final text, awaiting publication. Consultation closed/closes 2026-03-09. Expected 2027-07-10. Indicators for the seriousness of breaches and their classification into four levels of gravity, criteria for the level of fines and administrative measures, and a methodology for periodic penalty payments, for supervisors of the financial and non-financial sector alike. Approved by the General Board on 1 July 2026 for transmission to the Commission; final report published 8 July 2026. Adoption by the Commission and publication in the Official Journal still to follow. Source: https://www.amla.europa.eu/document/download/9bf678c2-a39b-4d6a-a12c-8cc6d5aca59c_en?filename=Final+Report+-+RTS+under+Article+53%2810%29+AMLD.pdf
- Regulatory Technical Standard: RTS on business relationships, occasional and linked transactions and lower CDD thresholds (Art. 19(9) AMLR). Status: Consultation closed, being finalised. Consultation closed/closes 2026-05-08. Expected 2026-09-30. Criteria for deciding when a contact becomes a business relationship, when transactions are occasional or linked, and which lower thresholds (below the EUR 10 000 default) trigger customer due diligence for higher-risk sectors and products. Consulted by AMLA from 9 February to 8 May 2026 (public hearing 24 March 2026). AMLA's programming document schedules the final draft for Q3 2026 and submission to the Commission in 2026; no final report yet. Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-rts-criteria-identifying-business-relationships-occasional-and-linked_en
- Regulatory Technical Standard: RTS on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries (Art. 16(4), 17(3) AMLR). Status: Consultation closed, being finalised. Consultation closed/closes 2026-06-15. Expected 2026-09-30. Minimum content of group-wide AML/CFT policies, procedures and controls, information sharing within the group, and the additional measures a group must take where a third country does not allow the group standard to be applied. Consulted from 16 April to 15 June 2026 (public hearing 20 May 2026); AMLA schedules the final draft for Q3 2026 and submission to the Commission in 2026. Until the RTS applies, Commission Delegated Regulation (EU) 2019/758 on measures in certain third countries stays in force. Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-rts-group-wide-minimum-requirements-and-additional-measures-subsidiaries-and_en
- Regulatory Technical Standard: RTS on the assessment of the inherent and residual risk profile of obliged entities in the non-financial sector (Art. 40(2) AMLD6). Status: In consultation. Consultation closed/closes 2026-09-27. Expected 2026-12-31. Common methodology for the supervisors of the non-financial sector (lawyers, notaries, accountants, tax advisers, trust and company service providers, real-estate agents, dealers in goods, gambling operators, football clubs and agents) to assess and classify the ML/TF risk profile of the entities they supervise: data points per activity, a reduced set for small entities, and the resulting risk categories. Consulted by AMLA from 13 July to 27 September 2026 (public hearing 10 September 2026); final draft scheduled for Q4 2026; AMLA intends the methodology to apply from 31 December 2028. Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-rts-assessment-inherent-and-residual-risk-profile-obliged-entities-non-financial_en
- Regulatory Technical Standard: RTS on the duties of home and host supervisors and the modalities of their cooperation (Art. 46(4) AMLD6). Status: Consultation closed, being finalised. Consultation closed/closes 2026-05-28. Expected 2026-09-30. How the supervisors of a cross-border group of obliged entities (financial and non-financial) divide their duties and cooperate: information exchange on their own initiative and on request, cross-border supervisory inquiries, common approaches such as coordinated or joint supervisory activities, and onward disclosure within the EU supervisory system without prior consent. AMLA consulted through a public hearing on 28 May 2026 (consultation paper of 11 May 2026; the hearing was the only channel for feedback). Final draft scheduled for Q3 2026; not published yet. Source: https://www.amla.europa.eu/events/public-hearing-draft-rts-home-host-supervisory-cooperation-2026-05-28_en
- Regulatory Technical Standard: RTS on cross-border information exchange between Financial Intelligence Units (Art. 31(3) AMLD6). Status: In consultation. Consultation closed/closes 2026-10-06. Expected 2026-12-31. Criteria for deciding when a report of suspicions concerns another Member State and how it is passed to that FIU: in full as a cross-border report, or as a set of key data as a cross-border dissemination, applied automatically within FIU.net. Consulted by AMLA from 6 July to 6 October 2026; final draft scheduled for Q4 2026. Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-rts-cross-border-information-exchange-between-financial-intelligence-units_en
- Regulatory Technical Standard: RTS on central contact points of e-money issuers, payment service providers and crypto-asset service providers (Art. 41(2) AMLD6). Status: EBA guideline in force, AMLA successor pending. Expected 2026-12-31. Criteria for when a host Member State may require an e-money issuer, payment service provider or crypto-asset service provider operating through agents, distributors or other infrastructure to appoint a central contact point, and the functions of that contact point. Statutory deadline 10 July 2026; AMLA schedules the consultation for Q3 2026 and the final draft for Q4 2026, and is running a survey among EMIs and PSPs until 22 September 2026 to prepare it. Until then Commission Delegated Regulation (EU) 2018/1108 applies; an EBA amendment to it awaits adoption by the Commission. Source: https://www.amla.europa.eu/news-media/news-articles/amla-launches-survey-central-contact-points_en
- Regulatory Technical Standard: RTS on AML/CFT supervisory colleges in the financial and the non-financial sector (Art. 49(14), 50(13) AMLD6). Status: Announced, no draft yet. Expected 2027-03-31. General conditions for the functioning of AML/CFT supervisory colleges for cross-border groups, in the financial sector (Art. 49) and, new, in the non-financial sector (Art. 50). Statutory deadline 10 July 2026; AMLA schedules the consultations for Q4 2026 and the final drafts for Q1 2027. Until then the joint ESA guidelines on AML/CFT colleges (2019) apply to financial supervisors. Source: https://www.amla.europa.eu/document/download/5ac4c728-9b4e-4416-b469-030f3fe32ce2_en?filename=Annex%20XI%20to%20AMLA%20SPD%202026-2028.pdf
- Regulatory Technical Standard: RTS on the AML/CFT central database (procedure, formats and timelines) (Art. 11(6) AMLAR). Status: Announced, no draft yet. Expected 2026-12-31. How supervisors feed AMLA's central AML/CFT database with information on obliged entities, weaknesses and measures, and how AMLA shares it. AMLA planned the consultation for Q2 2026 and the final draft for Q3 2026; a consultation package was expected at the General Board in September 2026. The EBA's central database (EuReCA, Delegated Regulation (EU) 2024/595) transferred to AMLA on 1 January 2026 and keeps operating until the new rules apply. Source: https://www.amla.europa.eu/document/download/5ac4c728-9b4e-4416-b469-030f3fe32ce2_en?filename=Annex%20XI%20to%20AMLA%20SPD%202026-2028.pdf
- Implementing Technical Standard: ITS on the format for reporting suspicions and providing transaction records to the FIU (Art. 69 AMLR). Status: Consultation closed, being finalised. Consultation closed/closes 2026-09-20. Expected 2026-12-31. Uniform EU format and data fields for reporting suspicious transactions (STR/SAR) to the FIU, with templates per type of obliged entity and a template for transaction records from credit and financial institutions. Consulted from 2 July to 20 September 2026 (public hearing 9 September 2026); the General Board asked for a proportionate, phased approach; final draft scheduled for Q4 2026. Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-its-format-reporting-suspicions-and-providing-transaction-records_en
- Implementing Technical Standard: ITS on cooperation within the AML/CFT supervisory system for the purposes of direct supervision (Art. 15(3) AMLAR). Status: Final text, awaiting publication. Consultation closed/closes 2026-01-27. How AMLA and national financial supervisors cooperate around direct supervision: the selection process (eligibility first, detailed data only from eligible entities), the publication of the selected entities, the transfer of supervisory tasks and powers when an institution moves to AMLA supervision (from 2028) or back to its national supervisor, and the joint supervisory teams. Consulted from 16 December 2025 to 27 January 2026 (AMLA's first public consultation); approved by the General Board on 1 July 2026 for transmission to the Commission; final report published 21 July 2026. Once adopted it governs the data collection and selection leading up to 2028. Source: https://www.amla.europa.eu/document/download/523b7780-4035-40c4-9d64-f1947ca0259a_en?filename=Final+report+-+ITS+under+Article+15%283%29+AMLAR.pdf
- Implementing Technical Standard: ITS on the format for FIU reporting to the European Public Prosecutor's Office (EPPO) (Art. 81(1) AMLR). Status: Final text, awaiting publication. Consultation closed/closes 2026-05-27. Expected 2027-07-10. Union-wide template and channel for FIUs to report the results of their analyses to the EPPO where there are reasonable grounds to suspect offences against the EU's financial interests: nine sections with mandatory and discretionary fields, machine-readable (XML) submission over a secure electronic channel, and an indication of the permitted use of the information. Consulted through a public hearing on 27 May 2026; approved by the General Board on 30 June 2026; final report published on 3 July 2026 and submitted to the Commission. Applies from 10 July 2027, machine-readable reporting from 10 July 2028. Source: https://www.amla.europa.eu/document/download/180688e2-9cbc-4b40-84ea-1f9121f4d32f_en?filename=Final%20Report%20-%20ITS%20under%20Article%2081%281%29%20AMLR.pdf
- Implementing Technical Standard: ITS on the format for AMLA reporting to the European Public Prosecutor's Office (EPPO) (Art. 41(2) AMLAR). Status: Final text, awaiting publication. Consultation closed/closes 2026-05-27. Expected 2027-07-10. The equivalent template for AMLA itself: how it reports the results of joint analyses with FIUs to the EPPO, in the same nine-section, machine-readable format over a secure electronic channel. Consulted through a public hearing on 27 May 2026; approved by the General Board on 30 June 2026; final report published on 3 July 2026 and submitted to the Commission. Applies from 10 July 2027, machine-readable reporting from 10 July 2028. Source: https://www.amla.europa.eu/document/download/993e4d38-eeef-4d9d-a3ec-85ff59f82d61_en?filename=Final%20Report%20-%20ITS%20under%20Article%2041%282%29%20AMLAR.pdf
- Implementing Technical Standard: ITS on the format for the exchange of information between Financial Intelligence Units (Art. 31(2) AMLD6). Status: Final text, awaiting publication. Consultation closed/closes 2026-05-27. Expected 2027-07-10. Six standard templates and minimum content for every FIU-to-FIU exchange over FIU.net: spontaneous exchanges, requests, responses, feedback, cross-border reports and cross-border disseminations, with simplified consent rules for the further use and dissemination of the information. Consulted through a public hearing on 27 May 2026; approved by the General Board on 30 June 2026; final report published on 3 July 2026 and submitted to the Commission. Certain requirements apply from 2027, machine-readable fields from 2028; FIU.net itself transfers to AMLA by 2027. Source: https://www.amla.europa.eu/document/download/db186a43-0976-4aab-aee5-f5a2dcf560e5_en?filename=Final%20Report%20-%20ITS%20under%20Art%2031%282%29%20AMLD.pdf
- Guideline: Guidelines on the business-wide risk assessment (SIRA) (Art. 10 AMLR). Status: Consultation closed, being finalised. Consultation closed/closes 2026-07-15. Expected 2026-12-31. Practical elaboration of the business-wide risk assessment: minimum content, method, review frequency and documentation, including the new risks the AMLR adds (targeted financial sanctions evasion). Consulted from 16 April to 15 July 2026 (public hearing 28 May 2026); AMLA aims to publish the final guidelines in 2026 (final draft scheduled for Q4 2026). Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-guidelines-business-wide-risk-assessment_en
- Guideline: Guidelines on ongoing monitoring and transaction monitoring (Art. 26 AMLR). Status: Consultation closed, being finalised. Consultation closed/closes 2026-09-03. Expected 2026-12-31. Requirements for ongoing monitoring of the business relationship in three parts: general principles, keeping customer information up to date, and the transaction and activity monitoring framework (scenario design, thresholds, alert handling, backtesting and model management). Consulted from 3 June to 3 September 2026 (public hearing 2 July 2026); AMLA aims to publish the final guidelines in 2026 (final draft scheduled for Q4 2026). Source: https://www.amla.europa.eu/policy/public-consultations/consultation-draft-guidelines-ongoing-monitoring-business-relationship_en
- Guideline: Guidelines on ML/TF risk variables and risk factors (successor to the EBA Risk Factors Guidelines) (Art. 20(3) AMLR). Status: EBA guideline in force, AMLA successor pending. Expected 2026-12-31. The risk variables and risk factors obliged entities take into account when entering into business relationships or carrying out occasional transactions, and how they weigh them in the customer risk assessment. Statutory deadline 10 July 2026; AMLA schedules the consultation for Q3 2026 and the final guidelines for Q4 2026, and intends one common set of Risk Factor Guidelines covering seven mandates, with a separate workstream for the indicators of suspicion (General Board, 30 June 2026). Until then the EBA ML/TF Risk Factors Guidelines (EBA/GL/2021/02, amended on 16 January 2024 for crypto-asset service providers) remain in force. Source: https://www.eba.europa.eu/sites/default/files/document_library/Publications/Guidelines/2023/EBA-GL-2023-03/1061654/Guidelines%20ML%20TF%20Risk%20Factors_conslidated.pdf.pdf
- Guideline: Guidelines on the extent of internal policies, procedures and controls (incl. the compliance function) (Art. 9(4) AMLR). Status: EBA guideline in force, AMLA successor pending. Expected 2027-06-30. The elements obliged entities take into account, given the nature, risks, complexity and size of their business, when deciding the extent of their internal policies, procedures and controls, in particular the staff allocated to the compliance function, and the situations in which the compliance manager and compliance officer roles may be simplified. Statutory deadline 10 July 2026; AMLA schedules the consultation for Q1 2027 and the final guidelines for Q2 2027 and set up a task force in July 2026. Until then the EBA Guidelines on the role and responsibilities of the AML/CFT compliance officer (EBA/GL/2022/05) remain in force. Source: https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/anti-money-laundering-and-countering-financing-1
- Guideline: Guidelines on the base amounts of pecuniary sanctions relative to turnover (Art. 53(11) AMLD6). Status: Announced, no draft yet. Expected 2026-12-31. Base amounts for pecuniary sanctions relative to turnover, broken down per type of breach and category of obliged entity, complementing the RTS on sanctions and measures. Statutory deadline 10 July 2026; AMLA schedules the consultation for Q2 2026 and the final guidelines for Q4 2026 and decided on 1 July 2026 to continue the work without extending its scope. No consultation paper yet. Source: https://www.amla.europa.eu/document/download/5ac4c728-9b4e-4416-b469-030f3fe32ce2_en?filename=Annex%20XI%20to%20AMLA%20SPD%202026-2028.pdf
- Guideline: Guidelines on targeted financial sanctions (internal policies, procedures and controls) (Art. 27 AMLR). Status: EBA guideline in force, AMLA successor pending. Expected 2027-06-30. AMLA's General Board agreed on 1 July 2026 to produce a comprehensive set of guidelines on targeted financial sanctions by the second quarter of 2027, as part of its cooperation strategy. Until then the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (14 November 2024, applying since 30 December 2025) apply to credit and financial institutions. Source: https://www.amla.europa.eu/document/download/225072ae-0e01-42ca-93dd-efa19beb8c67_en?filename=Public%20summary%209th%20SUP%20GB%20-.pdf
- Guideline: Joint AMLA-EDPB Guidelines on partnerships for information sharing (Art. 75 AMLR). Status: Announced, no draft yet. Expected 2027-07-10. Guidelines, drafted jointly with the European Data Protection Board, on how obliged entities may share information in partnerships to detect and report suspicious activity while protecting personal data. Announced on 1 July 2026: national authorities deliver proposals by the end of August 2026, drafting with the EDPB starts in September 2026, and AMLA plans a public consultation in the first half of 2027. Art. 75 AMLR applies from 10 July 2027. Source: https://www.amla.europa.eu/press-release-amla-and-edpb-develop-joint-guidelines-partnerships-information-sharing_en
- Guideline: Guidelines on outsourcing of AML/CFT tasks (Art. 18(8) AMLR). Status: Announced, no draft yet. Expected 2027-07-10. Which AML/CFT tasks may be outsourced and which may not (e.g. the business-wide risk assessment, the compliance functions and the decision to report), and the requirements for contracts, oversight and exit. Statutory deadline 10 July 2027; one of the 14 mandates AMLA plans to deliver in 2027. No consultation paper yet, and no EBA AML guideline exists on this topic. Source: https://www.amla.europa.eu/document/download/d6c051f9-5d55-463a-bafe-5161c4a16be9_en?filename=20260715%20ECON_LIBE%20Public%20Hearing%20-%20Opening%20Statement.pdf
- Guideline: Guidelines on reliance on other obliged entities for CDD (Art. 50 AMLR). Status: Announced, no draft yet. Expected 2027-07-10. Conditions under which reliance may be placed on customer due diligence performed by other obliged entities, the information and documents to obtain from them, and the responsibility that stays with the relying entity. Statutory deadline 10 July 2027; no consultation paper yet. Source: https://www.amla.europa.eu/document/download/d6c051f9-5d55-463a-bafe-5161c4a16be9_en?filename=20260715%20ECON_LIBE%20Public%20Hearing%20-%20Opening%20Statement.pdf
- Guideline: Guidelines on politically exposed persons (PEPs) (Art. 42(2) AMLR). Status: EBA guideline in force, AMLA successor pending. Expected 2027-07-10. Elaboration of prominent public functions, family members and close associates, the risk-based measures for PEPs and the measures after PEP status ends. Statutory deadline 10 July 2027; AMLA counts it among the risk-related mandates it plans for 2027. Until then the PEP provisions of the EBA Risk Factors Guidelines apply. Source: https://www.eba.europa.eu/sites/default/files/document_library/Publications/Guidelines/2023/EBA-GL-2023-03/1061654/Guidelines%20ML%20TF%20Risk%20Factors_conslidated.pdf.pdf
- Guideline: Guidelines on ML/TF risks, trends and methods involving third countries (Art. 32(1) AMLR). Status: Announced, no draft yet. Expected 2027-07-10. Guidelines defining the ML/TF risks, trends and methods involving geographical areas outside the Union to which obliged entities are exposed, next to the Commission's delegated acts that identify high-risk third countries (Art. 29-31). Statutory deadline 10 July 2027; no consultation paper yet. Source: https://www.amla.europa.eu/document/download/d6c051f9-5d55-463a-bafe-5161c4a16be9_en?filename=20260715%20ECON_LIBE%20Public%20Hearing%20-%20Opening%20Statement.pdf
- Guideline: Guidelines on EDD for correspondent relationships with crypto-asset service providers and on self-hosted addresses (Art. 37(3), 40(2) AMLR). Status: EBA guideline in force, AMLA successor pending. Expected 2027-07-10. Criteria for the assessment of respondent crypto-asset service providers in correspondent-type relationships and the mitigating measures for transactions with self-hosted addresses. Statutory deadline 10 July 2027; no consultation paper yet. Until then the crypto provisions of the EBA Risk Factors Guidelines (amended 2024) and the EBA Travel Rule Guidelines apply; see also AMLA's advisory note of 29 June 2026 on the end of the MiCAR transitional period. Source: https://www.eba.europa.eu/legacy/regulation-and-policy/regulatory-activities/anti-money-laundering-and-countering-financing-1
- Guideline: Guidelines on establishing the wealth of high-net-worth customers (Art. 34(5) AMLR). Status: Announced, no draft yet. Expected 2027-07-10. How credit and financial institutions and trust or company service providers establish whether a customer holds total assets of at least EUR 50 million (excluding the private residence) and how to determine that value, which triggers the enhanced measures of Art. 34(5) for relationships handling at least EUR 5 million. Statutory deadline 10 July 2027; no consultation paper yet, and no EBA guideline exists on this topic. Source: https://www.amla.europa.eu/document/download/d6c051f9-5d55-463a-bafe-5161c4a16be9_en?filename=20260715%20ECON_LIBE%20Public%20Hearing%20-%20Opening%20Statement.pdf
- Guideline: Joint AMLA-EBA Guidelines on access to financial services and de-risking (Art. 21(4) AMLR). Status: EBA guideline in force, AMLA successor pending. Expected 2027-07-10. Joint guidelines with the EBA on the measures credit and financial institutions may take to comply with AML/CFT rules when applying the Payment Accounts Directive, including for relationships most affected by de-risking. Statutory deadline 10 July 2027; the EBA continues its de-risking guidelines jointly with AMLA (transition factsheet). Until then the EBA Guidelines on the effective management of ML/TF risks when providing access to financial services (31 March 2023) apply. Source: https://www.eba.europa.eu/legacy/regulation-and-policy/regulatory-activities/anti-money-laundering-and-countering-financing-6
- Guideline: Guidelines on indicators of suspicious activity or behaviour (Art. 69(5) AMLR). Status: Announced, no draft yet. Expected 2027-07-10. Indicators of suspicious activity or behaviour, to be updated periodically, supporting the AMLR's suspicion-based reporting standard. Statutory deadline 10 July 2027 ("by July 2027" in AMLA's programming document); AMLA runs it as a dedicated workstream within the common Risk Factor Guidelines. No consultation paper yet. Source: https://www.amla.europa.eu/amla-sets-strategic-priorities-2026-28-single-programming-document_en
- Guideline: EBA Guidelines on the use of remote customer onboarding solutions (in force until replaced) (Directive (EU) 2015/849 (AMLD5), art. 13(1)). Status: Published. Steps for verifying a customer's identity remotely, the safeguards for the technology and its outsourcing, and the documentation to keep (EBA/GL/2022/15, published 22 November 2022, applying since 2 October 2023). AMLA lists it among the EBA instruments that continue to apply under Art. 54(5) AMLAR; the AMLR successor is the RTS on CDD, which sets the verification sources including eID and the EU Digital Identity Wallet. Source: https://www.eba.europa.eu/legacy/regulation-and-policy/regulatory-activities/anti-money-laundering-and-countering-financing-4
- Guideline: EBA Travel Rule Guidelines: information accompanying transfers of funds and crypto-assets (in force) (Regulation (EU) 2023/1113 (TFR), art. 36). Status: Published. Which information must travel with a transfer of funds or crypto-assets, how payment service providers and crypto-asset service providers detect missing or incomplete information and what they do with such transfers (published 4 July 2024, applying since 30 December 2024). The Transfer of Funds Regulation is not replaced by the AML package; AMLA lists the guidelines among the instruments that continue to apply. Source: https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/anti-money-laundering-and-countering-financing-terrorism/guidelines-information-requirements-relation-transfers-funds-and-certain-crypto-assets-transfers
- Dutch national guidance: Implementatiewet AML-pakket (Dutch implementation act for AMLD6) (AMLD6 (whole)). Status: In consultation. Expected 2027-07-10. National act that transposes AMLD6, amends or repeals the Wwft and designates DNB, AFM and BFT as supervisors under the new regime. Determines which national options (cash limits, register access, sanctions) the Netherlands keeps. Source: https://www.rijksoverheid.nl/onderwerpen/witwassen
- Dutch national guidance: DNB Leidraad Wwft en Sanctiewet (current guidance) (Wwft, Sw 1977). Status: Published. DNB guidance on the risk-based approach, customer due diligence, transaction monitoring, sanctions screening and governance under the Wwft and the Sanctiewet. Expected to be withdrawn or rewritten when AMLA guidelines apply. Source: https://www.dnb.nl/voor-de-sector/open-boek-toezicht/wet-regelgeving/wwft/
- Dutch national guidance: AFM Wwft guidance for investment firms, fund managers and CASPs (Wwft). Status: Published. AFM guidance and Q&As on Wwft compliance for the institutions it supervises, including the transition of crypto-asset service providers to MiCA licensing. Source: https://www.afm.nl/
- Dutch national guidance: FIU-Netherlands reporting guidance and goAML specifications (Wwft art. 16; AMLR Art. 69). Status: Published. Reporting indicators (objective and subjective), goAML schema and guidance for reporting unusual transactions. Will change when the AMLR suspicion standard and the ITS template apply. Source: https://www.fiu-nederland.nl/
- Dutch national guidance: Dutch list of prominent public functions (Ministry of Finance) (AMLR Art. 43). Status: Published. National list of functions that qualify as prominent public functions for domestic PEP identification. Source: https://www.rijksoverheid.nl/onderwerpen/witwassen

## Milestones

- 2024-06-19: AML package published in the Official Journal. AMLR, AMLD6 and AMLAR published; entered into force 9 July 2024. AMLA has legal existence since 26 June 2024.
- 2025-03-06: EBA consults on four RTS under the AML package. On the Commission's request the EBA consulted the RTS on CDD, on the risk assessment of obliged entities, on AMLA selection and on sanctions (closed 6 June 2025) and delivered its advice on 31 October 2025. AMLA re-consulted three of them in 2026 to hear the non-financial sector.
- 2025-07-01: AMLA operational in Frankfurt. AMLA became operational on 1 July 2025 (Art. 108 AMLAR); the Commission remained responsible for its establishment until 31 December 2025.
- 2025-12-16: First two final RTS and AMLA's first public consultation. Final reports on the RTS on the risk profile of financial institutions (Art. 40(2) AMLD6) and on the selection for direct supervision (Art. 12(7) AMLAR), sent to the Commission; consultation on the ITS on supervisory cooperation opened (until 27 January 2026).
- 2026-01-01: EBA hands over its AML/CFT mandates to AMLA. All AML/CFT mandates and functions, including the EuReCA database, transferred from the EBA to AMLA. Existing EBA guidelines and standards remain in force until AMLA replaces them (Art. 54(5) AMLAR).
- 2026-02-04: Single Programming Document 2026-2028: 24 of 40 mandates planned for 2026. Annex XI gives the consultation and final-draft quarter per RTS, ITS and guideline; the expected dates in this register follow it. AMLA adjusted several statutory deadlines in it.
- 2026-07-10: Statutory deadline for the first tranche of RTS, ITS and guidelines. Deadline in the AMLR and AMLD6 for the RTS on CDD, thresholds, group-wide requirements, sanctions, home-host cooperation and FIU exchange, the STR and EPPO formats and the guidelines on the business-wide risk assessment, risk factors, internal controls and monitoring. Delivered by then: the selection and risk RTS (December 2025), the sanctions RTS and the three FIU/EPPO formats (July 2026), the supervisory cooperation ITS (21 July 2026). The other final drafts are scheduled for Q3-Q4 2026 or 2027.
- 2026-08-15: Eligibility data for direct supervision due at AMLA. National supervisors deliver the data on provisionally eligible credit and financial institutions (six or more Member States, reference date 31 December 2025); AMLA expects the provisional list by the end of September 2026.
- 2026-12-31: AMLA's delivery target for 2026. Per the programming document: RTS on CDD, thresholds and group-wide requirements to the Commission; guidelines on the business-wide risk assessment, risk factors and ongoing monitoring published; selection and risk RTS finalised with the Commission; first joint analyses in the fourth quarter.
- 2027-01-01: Data collection for the 2027 selection (January to March). Provisionally eligible institutions report the selection data through their national supervisor, reference date 31 December 2026, in the EBA reporting framework 4.4.
- 2027-07-01: AMLA starts the first selection for direct supervision. Selection of up to 40 cross-border credit and financial institutions from 1 July 2027 (Art. 13(4) AMLAR); the outcome is communicated by the end of 2027 and repeated every three years.
- 2027-07-10: AMLR applies / AMLD6 transposition deadline. All AMLR obligations apply directly, including the information-sharing partnerships of Art. 75. Most AMLA guidelines with a 2027 deadline are due by the same date.
- 2028-01-01: AMLA direct supervision starts during 2028. Direct supervision begins six months after publication of the selection list (Art. 13(4) AMLAR); AMLA says "during 2028". Shown at 1 January as the earliest date.
- 2029-07-10: AMLR obligations for football clubs and agents. Later application date for the newly added sectors.

## Beyond 10 July 2027

- Now - Prepare: Gap analysis against the AMLR text, redesign of onboarding, monitoring and reporting, and responses to AMLA consultations while the RTS, ITS and Guidelines are still being finalised.
- 10 Jul 2027 - AMLR applies: The AMLR obligations apply directly. National supervisors (in the Netherlands DNB, AFM and BFT) supervise under the AMLD6 implementation act. First supervisory reviews test the new customer due diligence, beneficial-ownership and reporting processes.
- 2028 - AMLA direct supervision: AMLA directly supervises the first group of up to 40 cross-border financial institutions selected in 2027, through joint supervisory teams with the national supervisors. AMLA can also take over supervision of other entities in specific cases and coordinates the supervisory colleges.
- 10 Jul 2029 - Football sector: Professional football clubs and agents become obliged entities. Institutions serving them adjust their risk assessment and due diligence.
- Ongoing - Maintain: AMLA keeps issuing and revising Guidelines, Q&As and technical standards; the Commission updates the high-risk third-country list and runs the supranational risk assessment. Compliance shifts from a project to a standing register of obligations, reviews and findings.

### Recurring obligations after go-live

- Business-wide risk assessment (SIRA) (At least yearly, and after material change): Review and update the business-wide risk assessment and the resulting policies; approve at management-body level.
- Periodic customer reviews (Per risk class (high risk yearly)): Refresh due diligence per risk class within the maximum review periods set in the RTS and Guidelines.
- Compliance reporting to the management body (At least yearly): The compliance officer reports on the effectiveness of internal policies, findings and remediation; the compliance manager owns follow-up.
- Suspicious transaction reporting (Continuous): Report suspicions to the FIU in the ITS template, respond to FIU requests and suspension orders, and keep the tipping-off controls in place.
- Training and awareness (Yearly and at onboarding): Train staff on the AMLR obligations, typologies and internal procedures; keep records of who was trained on what.
- Regulatory watch (Continuous (this site checks sources daily)): Track new and revised AMLA Guidelines, Q&As, RTS/ITS revisions and Commission delegated acts, and map them to the framework blocks they change.
- Supervisory data and AMLA selection (Selection rounds every three years): Deliver the data used for AMLA's periodic selection of directly supervised entities and answer supervisory information requests.
- Record retention and data protection (Continuous): Keep due-diligence and transaction records for five years after the end of the relationship, then delete them, within national data-protection practice.

## Frequently asked questions

### What is the AMLR?

The AMLR is Regulation (EU) 2024/1624, the EU Anti-Money Laundering Regulation. It is the "single rulebook" of the EU AML package: directly applicable customer due diligence, beneficial ownership, internal control and reporting obligations for obliged entities across the EU. It applies from 10 July 2027.

### When does the AMLR apply?

The AMLR applies from 10 July 2027 (Article 90). Football clubs and agents follow from 10 July 2029. The same date, 10 July 2027, is the transposition deadline of the Sixth Anti-Money Laundering Directive (AMLD6, Directive (EU) 2024/1640).

### What is the difference between an RTS, an ITS and a Guideline?

A Regulatory Technical Standard (RTS) is a binding delegated act that specifies how an AMLR article must be applied; AMLA drafts it and the European Commission adopts it. An Implementing Technical Standard (ITS) is a binding act that sets formats and templates, such as the template for reporting suspicious transactions. Guidelines are issued by AMLA on a comply-or-explain basis and set supervisory expectations without being directly binding law.

### Who is AMLA?

AMLA is the Authority for Anti-Money Laundering and Countering the Financing of Terrorism, established by Regulation (EU) 2024/1620 and based in Frankfurt. It became operational in 2025, develops the RTS, ITS and Guidelines under the AML package, and will directly supervise a first group of up to 40 cross-border financial institutions from 2028.

### What does "RTS in consultation" mean?

A draft RTS has been published for public consultation. Obliged entities and industry bodies can respond until the consultation closes. After that the draft is finalised, submitted to the European Commission and adopted as a delegated regulation, then published in the Official Journal of the EU.

### What changes for Dutch institutions compared with the Wwft?

Most Wwft obligations are replaced by the directly applicable AMLR; the Dutch implementation act keeps national elements such as supervision by DNB, AFM and BFT, FIU-Netherlands reporting and possibly lower cash limits. Key changes include suspicion-based reporting instead of "unusual transaction" indicators, an EU-wide beneficial ownership threshold, a board-level compliance manager and harmonised enhanced due diligence.

### What happens after 10 July 2027?

From 10 July 2027 the AMLR obligations apply and national supervisors review compliance under the AMLD6 implementation act. From 2028 AMLA directly supervises a first group of up to 40 cross-border financial institutions selected in 2027, with new selection rounds every three years. From 10 July 2029 football clubs and agents are covered. AMLA keeps issuing and revising Guidelines, Q&As and technical standards, so compliance becomes a standing cycle of risk assessments, periodic customer reviews, reporting and training rather than a one-off project.

### What can I do with AMLR Monitor?

The public dashboard shows the status of every RTS, Guideline and ITS under the AMLR, filtered by type of obliged entity, mapped onto a compliance framework with article links and "what changes" notes. The workspace (free account per organisation) adds a company profile with an AI impact assessment, a readiness tracker shown as a heat map, country-specific points for every EU country, an AI consultant that knows your organisation, consultation tracking, daily source alerts, tasks, a team, exports and a board report.

### How often is this dashboard updated?

Regulatory statuses are reviewed manually and dated on the page. In addition, an automated check fetches the EBA, AMLA, EUR-Lex and DNB source pages every day and lists any new AML-related publication for signed-in users in the workspace.

### Who must comply with the AMLR?

Every obliged entity in Article 3 AMLR: credit and financial institutions, payment and e-money institutions, investment firms and fund managers, life insurers, crypto-asset service providers, crowdfunding platforms, trust and company service providers, accountants, tax advisers, lawyers and notaries for listed transactions, estate agents, dealers in high-value goods, gambling operators and, from 2029, professional football clubs and agents. The overview page lists every type with its scope.

### What is the AMLR cash limit?

Traders in goods and services may not accept cash payments of 10,000 euro or more (Article 80 AMLR). Member States may set a lower limit; the Netherlands has 3,000 euro. Payments between private individuals and payments at credit, payment and e-money institutions are excluded.

### What is the beneficial ownership threshold under the AMLR?

25 percent of shares, voting rights or other ownership interest, directly or indirectly, plus control through other means such as veto rights or the power to appoint the majority of the board (Articles 51 to 56). Member States may set a lower threshold for high-risk sectors.

### Does the AMLR apply to crypto-asset service providers?

Yes. MiCA-licensed CASPs are obliged entities under the AMLR with specific enhanced due diligence for cross-border correspondent relationships and self-hosted addresses (Articles 37 and 38), next to the Transfer of Funds Regulation travel rule.

### What do the statuses on the dashboard mean?

In consultation: a draft is open for comment. Consultation closed, being finalised: AMLA processes the responses. Final text, awaiting publication: adopted or submitted to the Commission, not yet in the Official Journal. EBA guideline in force, AMLA successor pending: the current EBA guideline applies today; AMLA's replacement under the AMLR is not yet consulted on or published. Published: in force or applying from the date shown.

## Official sources

- [AMLR - Regulation (EU) 2024/1624 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2024/1624/oj)
- [AMLD6 - Directive (EU) 2024/1640 (EUR-Lex)](https://eur-lex.europa.eu/eli/dir/2024/1640/oj)
- [AMLAR - Regulation (EU) 2024/1620 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2024/1620/oj)
- [AMLA - Authority for Anti-Money Laundering](https://www.amla.europa.eu/)
- [AMLA - regulatory instruments overview (RTS, ITS, Guidelines)](https://www.amla.europa.eu/policy/regulatory-instruments_en)
- [AMLA - public consultations (open and closed)](https://www.amla.europa.eu/policy/public-consultations_en)
- [EBA - AML/CFT regulation and policy](https://www.eba.europa.eu/regulation-and-policy/anti-money-laundering-and-countering-financing-terrorism)
- [DNB - Wwft and the EU AML package](https://www.dnb.nl/voor-de-sector/open-boek-toezicht/wet-regelgeving/wwft/)